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CBOECboe Global Markets

Financials · Exchanges & Brokers · CBOE
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SEC comment letters, last 20 years

1 review of CBOE's filings by SEC staff

UPLOAD and CORRESP
ReviewsRead ↓
1
latest letter 2018-04-02
Questions asked
2
each answered in the company's own letter
No closing letter
0
reviews without a letter saying the staff completed it

When the SEC's staff reviews a filing, it writes to the company with numbered questions, and the company answers each one in a letter. SEC publishes the exchange once the review is over, at least 20 business days later. A question is not an accusation; most reviews end with the company adding detail to its next filing.

Form 10-K for the fiscal year ended December 31, 2017

2018-04-02 to 2018-05-02 · 2 questions · 2 letters from the SEC, 2 from the company
Review closed 2018-05-02
Non-GAAP measuresAcquisitions
Exhibit 99.1 · Combined Reconciliations, page 13
SEC asked
We note your presentation of adjusted combined income statement reconciliations for the twelve months ended December 31, 2017 and 2016 and the three months ended December 31, 2016. Please tell us how your presentation complies with Question 102.10 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations issued on October 17, 2017.
CBOE answered
We respectfully acknowledge the Staff’s comment regarding the adjusted combined income statement reconciliation on page 15 of Exhibit 99.1. In response to the Staff’s comment, we will revise the adjusted combined income statement reconciliation section of our earnings release filed as Exhibit 99.1 (the “Exhibit”) to Form 8-K in future filings to exclude net revenue line items and other line items not impacted by non-GAAP adjustments.
Rest of the answer

We will also change the formatting of the schedule to make it evident that the Exhibit is not an income statement by moving the non-GAAP reconciliation line items below the combined results presentation.

We acknowledge our responsibility for the accuracy and adequacy of our disclosures. If you have any questions or would like to discuss this response, please contact the undersigned at 312-786-5600.

Read in the reply ↗
In its next report

First report after the company's reply of 2018-04-13: 10-Q filed 2018-05-04 ↗, against the 10-Q filed 2017-11-07 ↗.

Tickdelta does not hold the text of both reports, so they are not compared here.

Exhibit 99.1 · Combined Reconciliations, page 13
SEC asked
We note from your response to our prior comment that you propose to revise your presentation of your adjusted combined income statement reconciliation in your earnings release, which will still include a presentation of your combined results as if the Bats acquisition occurred at the beginning of the period(s) presented.
Rest of the question

Please clarify if these combined results represent a pro forma presentation under Article 11 of Regulation S-X as we note your disclosure on page 14 states that results on a combined basis are non- GAAP. Include within your response your proposed presentation in a tabular format.

CBOE answered
In response to the Staff’s comment, we advise that the combined results are presented on a non-GAAP basis and do not represent a pro forma presentation under Article 11 of Regulation S-X. We believe that the non-GAAP financial measures presented provide additional and comparative information to assess trends in our core operations and a means to evaluate period-to-period comparisons. These non-GAAP financial measures are provided as additional information to the investors.
Rest of the answer

Please see the proposed updated form of tabular format in the attached Exhibit A.

We acknowledge our responsibility for the accuracy and adequacy of our disclosures. If you have any questions or would like to discuss this response, please contact the undersigned at 312-786-5600.

Read in the reply ↗
In its next report

First report after the company's reply of 2018-05-01: 10-Q filed 2018-05-04 ↗, against the 10-Q filed 2017-11-07 ↗.

Tickdelta does not hold the text of both reports, so they are not compared here.

Also in this review: closing letter, 2018-05-02

Other letters

Letters without questions

UPLOAD and CORRESP
4 other letters: notices that a filing will not be reviewed, requests to declare a registration effective, and the like

From the SEC's correspondence on EDGAR: staff letters (form UPLOAD) and company letters (form CORRESP), 20 letters filed since 2015-05-27. Questions and answers are matched by their numbers; topics come from words in each question. The reports are compared word for word (same form, before the first SEC letter against the first report after the company's reply). No AI.

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